U.S. Nuclear Regulatory Commission
Clarification of Certain Requirements for Exclusive-Use Shipments of Radioactive Materials
Title: Clarification of Certain Requirements for
Exclusive-Use Shipments of Radioactive Materials
See IE Information Notice No. 80-32 dated August 29, 1980.
This notice clarifies requirements regarding open and
closed transport vehicles, personnel barriers, packages
enclosed within an outer cask shield, exclusive-use
shipments, and radiation limits. See Revision 1 to this IE
information notice (HPPOS-085).
In mid-1979, NRC initiated an enhanced program for
inspection of shipments of radiation materials. This
augmented inspection / enforcement program prompted a number
of questions on the proper application of certain
regulatory requirements. These questions involved the
problems and deficiencies associated with exclusive-use
highway shipments of low-level radioactive wastes. The
purpose of this Notice is to discuss the following fourteen
questions to clarify the application of certain
requirements, particularly the application of the limits of
radiation levels of exclusive-use shipments as prescribed
in 49 CFR 173.393 (j).
1.What limits would apply to packages being transported on
an open, exclusive-use transport vehicle?
2.What constitutes a closed transport vehicle?
3.In the situation described above, is such a "personnel
barrier" considered to be the "package" or a component of
4.In the above situation, what are the limits for radiation
levels on the packages within such a personnel barrier?
5.If "packages" such as drums are enclosed within an outer
cask "shield" (as opposed to a personnel barrier or closed
vehicle) wherein the other shield is necessary to achieve
compliance with the limit of either 173.393 (i) or 173.393
(j), may the inner drum (s) be considered to be the
6.In the situation described above, would the levels of
radiation on the inner drums be limited to the levels of
173.393 (j) (1) (e.g., 1000 mrem/hr at 3 ft)?
7.In monitoring the radiation levels at the external
surface of the transport vehicle, as prescribed in 173.393
(j) (2), do the limits apply at the bottom and top of the
vehicle, as well as at the sides?
8.In the above situation, does this mean that in applying
the limit of 173.393 (j) (3) (e.g., 10 mrem/hr at 6 ft from
the sides of the vehicle) the limit also applies at the top
and "bottom" of the vehicle?
9.In 173.393 (j) (3) the radiation level limit is
prescribed at 10 mrem/hr at 2 m (6 ft) from the outer
lateral surfaces of an exclusive-use vehicle. Since 2 m is
6.6 ft, which limit would apply (6 ft or 6.6 ft)?
10.What is an "exclusive-use" shipment?
11.Frequently shipments of radioactive waste are made as
"exclusive-use" shipments under arrangements whereby the
original generator of the waste utilizes the services of a
waste collector (i.e., "broker) who in turn usually engages
a common or contract carrier to transport the shipment or
transport the material in his own vehicle as a private
carrier. On occasion this "broker" may also be the
consignee (e.g., a waste burial site operator). Because of
this complex arrangement, confusion often arises as to
which party is responsible for performing the regulatory
requirements of the "shipper" or "consignor." Can you
12.In the above situation, assume that a "broker" picks up
or arranges for pickup radioactive waste from more than one
generator's facility for transport as a single shipment by
a common carrier or by himself as a private carrier. Is it
not required that an exclusive-use shipment be from a
13.In an exclusive-use shipment of LSA materials, the
shipper is required by 173.392 (c) (9) to provide specific
instructions to the carrier for maintenance of
exclusive-use shipment controls. What should such specific
14.49 CFR 173.393 (j) (4) requires that the radiation level
in any "... normally occupied position in the car or
vehicle ..." be limited to 2 mrem/hr. Where should this
limit be applied in a tractor with a sleeper cab?
Regulatory references: 10 CFR 71, 49 CFR 173
Subject codes: 7.1, 12.17